On November 4, 2009, Mr. Cacapit attempted to contact Mr. Johnson by phone
<br /> regarding the 48-hour notification for the August 14, 2009 secondary containment
<br /> testing. There was no answer.
<br /> On November 5, 2009, Mr. Cacapit sent another follow up fax to Mr. Khajevandi asking
<br /> for a return to compliance certification and corrective actions statement for the
<br /> November 17, 2008, hazardous waste inspection report (Attachment 28).
<br /> On November 6, 2009, Mr. Cacapit spoke to Mr. Johnson and asked about the 48-hour
<br /> notification. Mr. Johnson stated that he remembered that he was supposed to send
<br /> documentation that he provided notification for the testing, and that he would send it that
<br /> day.
<br /> On November 17, 2009, Mr. Cacapit sent a letter to the facility informing Mr. Khajevandi
<br /> and Ms. Haleh Amiri, Partner, that the EHD has rejected the August 14, 2009, secondary
<br /> containment test results and that testing would have to be immediately scheduled, 48-
<br /> hour notification provided to the EHD, and completed (Attachment 29).
<br /> On December 3, 2009, notification for secondary containment testing on December 7,
<br /> 2009, was submitted (Attachment 30).
<br /> On December 4, 2009, lab analysis for soil cuttings, disposal receipt for two drums of
<br /> soil cuttings, and a disposal receipt for a container of used oil filters was submitted
<br /> (Attachment 31). A corrective actions statement for the November 8, 2008, hazardous
<br /> waste inspection and disposal receipts for two containers found on site during the July
<br /> 30, 2008, but not during the November 8, 2008, inspection were still lacking.
<br /> On December 29, 2009, a secondary containment test report was submitted for testing
<br /> performed on December 7, 2009 (Attachment 32).
<br /> On July 26, 2010, Mr. Jeffrey Wong, Senior REHS, EHD, performed a routine hazardous
<br /> waste inspection (Attachment 33). A monitoring system certification was also scheduled
<br /> for the day, but the testing company called to reschedule after Mr. Wong had arrived on
<br /> site. During the inspection, Mr. Wong found a 55-gallon container labeled "Drained
<br /> Used Oil and Gasoline Filters" that contained three filters, a used dispenser nozzle and
<br /> hose, and approximately 15-20 gallons of oily liquid. Eight universal waste fluorescent
<br /> bulbs were not stored in a closed container and it could not be determined how long the
<br /> lamps had been stored. Photos are attached (Attachment 34).
<br /> On July 28, 2010, Mr. Cacapit performed a routine UST inspection and witnessed the
<br /> monitoring system certification, leak detector testing, and spill container testing. The 91-
<br /> octane fill sump sensor failed when tested (and was replaced on site), leaks were found
<br /> in dispensers 5/6 and 9/10, and approximately one quart of liquid was found in the 91-
<br /> octane piping sump and approximately '/2 gallon of liquid was found in the diesel piping
<br /> sump. During a review of the facility's paperwork, Mr. Cacapit found that secondary
<br /> containment was last performed five months late and financial responsibility documents
<br /> were submitted one month late. The UST operating permit and maintenance records for
<br /> nine alarms were not found on site. In the designated operator monthly inspection
<br /> reports, two alarms were not documented in the monthly inspection reports and
<br /> secondary containment test dates were incorrectly noted. Mr. Khajevandi was working
<br /> alone and he did not have current training by the designated operator. Mr. Cacapit did
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